The Transformation Fund

Funding for township and rural black entrepreneurs

A R120 billion fund that puts capital directly into the hands of black entrepreneurs in townships and the rural economy. It offers companies a simple alternative to the B-BBEE scorecard.

The Proposal in Brief

Four pillars

01GOVERNANCE

A credible leader

Appoint a credible leader to drive confidence in the fund. The market will judge the fund by the reputation of the person who runs it. An example is Sim Tshabalala, CEO of Standard Bank.

02STRUCTURE

Mirror the PIC

Mirror the structure of the Public Investment Corporation. Place the fund under the DTIC. Amend the mandate so it funds black-owned venture capital funds.

03BENEFICIARIES

Township and rural entrepreneurs

Mandate that all funding goes to township and rural entrepreneurs. This means businesses in townships and low-income communities, and in the rural economy — agriculture, tourism, conservation and rural enterprise. Keep the application process simple and quick.

04FUNDING

R120 billion via a turnover levy

Raise R120 billion. Offer companies an alternative to the scorecard: a 3% levy on turnover, collected by SARS. In exchange, a Level 3 B-BBEE certificate. Zero complexity.

Why It Works

Seven benefits

1

Builds market confidence in the fund's competence and integrity

2

Widens the net of companies participating in B-BBEE

3

Raises meaningful sums

4

Simplifies business

5

Seeds a black-owned venture capital industry

6

Funds township and rural entrepreneurs

7

Spurs township and rural economic growth

The Case for Change

What works, and what does not

B-BBEE has been a success. It has shifted ownership, built management diversity and contributed to economic growth. The policy must continue.

But two problems remain.

For all businesses

Compliance is complex. The scorecard creates administrative cost and distraction. It deters investment and slows new business formation.

For black-owned businesses

Access to affordable capital remains a critical constraint. The existing framework has not solved this.

BEE3 addresses both. A simple levy for those who choose it. A capable fund that places that capital in the hands of black entrepreneurs.

The Mechanics

How the levy works

3%

levy on gross revenue

collected by SARS

A 3% levy on gross revenue, collected by SARS. In return, a Level 3 B-BBEE certificate.

The levy is voluntary and offered as an alternative to the existing scorecard, not a replacement. Level 1 remains achievable by meeting employment equity targets in addition.

What the levy satisfies:
51% black ownership requirement
Enterprise and supplier development
Socio-economic development
Employment equitystill required separately
Employee share ownership (ESOP)not included
Result

Level 3 B-BBEE certificate

The Numbers

Why revenue, and where R120 billion comes from

Why revenue, not profit

The levy is calculated on revenue. Revenue is hard to game. Profit can be reduced through accounting choices — expense classification, transfer pricing, depreciation policy. Revenue cannot be reduced in the same way. SARS already tracks it for VAT.

For a company with a 20% margin, the levy is modest:

RevenueR100 million
Profit (20% margin)R20 million
Company tax (27% of profit)R5.4 million
Transformation levy (3% of revenue)R3 million
Total taxR8.4 million
Effective tax rate42%

Where R120 billion comes from

Formal business revenue in South Africa was about R12.7 trillion in 2022. JSE-listed companies accounted for around R4 trillion. Unlisted companies accounted for around R8.7 trillion.

Assume 15% of unlisted revenue is not B-BBEE compliant. That is R1.35 trillion. A 3% levy on that base yields about R40 billion a year. Over three years, R120 billion.

Total formal business revenue (2022)~R12.7 trillion
JSE-listed~R4 trillion
Unlisted~R8.7 trillion
Of which non-compliant (assume 15%)~R1.35 trillion
3% levy per year~R40 billion
Over three years~R120 billion

For comparison, current Enterprise and Supplier Development contributions from the same companies — calculated at 3% of NPAT, on an assumed 10% margin — total roughly R4 billion a year. The proposed levy raises about ten times that.

The Fund

How the fund will be run

The fund sits under the DTIC and mirrors the Public Investment Corporation: an arms-length entity with professional management. Three principles guide its mandate.

Fund black entrepreneurs

Capital goes to black-owned businesses in townships and the rural economy. Not to government departments. Not as grants. To entrepreneurs.

Soft financing, not hand-outs

Interest-free loans and convertible notes. Capital is repaid and recycled into the next business. Terms more affordable than commercial funding, but capital that returns.

Deploy, do not hoard

Fund managers are penalised for holding cash. The point is to place capital with entrepreneurs who need it, not to protect it from risk.

The fund operates as a fund of funds. It deploys capital through a network of black-owned venture capital fund managers, who in turn invest in black entrepreneurs. The DTIC sets policy. Professional managers make the investment decisions. Reporting is public.

Scope

What this proposal does and does not do

1

Eligibility

The levy is available only to non-JSE-listed companies. JSE-listed entities continue to follow the existing B-BBEE scorecard.

2

Voluntary

The levy is voluntary. Companies choose between the existing scorecard and the levy. Neither is imposed.

3

Complement, not replacement

The proposal sits alongside existing B-BBEE legislation. It does not replace it.

Formal Submission

The Kululeko submission to the DTIC

Dated 4 March 2026

The Kululeko Institute made a formal submission to the DTIC on the proposed Transformation Fund funding mechanism.

The core argument is simple. A levy on turnover is simpler, harder to game and raises more than a mechanism based on net profit after tax (NPAT). Profit can be reduced through accounting choices; turnover cannot, in the same way that VAT cannot.

A turnover levy is simpler, harder to game, and raises more than an NPAT-based mechanism.

The submission urges the DTIC to build the fund on the PIC template, appoint a credible leader, focus funding on black entrepreneurs in townships, and radically simplify compliance to widen the net of contributing companies.

Read the full submission
Questions

Frequently asked questions

Downloads

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Summary recommendations

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Full submission to the DTIC

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Transformation whitepaper

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